Chhattisgarh High Court
Civil Procedure and EvidenceProperty and Real Estate Law

Writ petitions become infructuous after parties settle the land dispute through a civil court decree.

Devnarayan Patel vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: October 16, 20261 MIN READSOURCE JUDGMENT
Writ petitions become infructuous after parties settle the land dispute through a civil court decree.. Devnarayan Patel vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners challenged a common order dated 5 August 2021 directing that the subject lands be recorded in the names of private respondents 5 and 6. They alleged the order was made without notice or hearing, despite the lands having been mutated in their names

Source reference: para. 2

The petitioners did not appear to press the petitions. Counsel for respondents 5 and 6 stated that the parties had settled the dispute and that Civil Suit No. 43-A/2021 had been disposed of by a compromise judgment and decree dated 1 September 2026

Source reference: paras. 3–4

The High Court considered the compromise decree

Source reference: paras. 5–6
02

Issues

1. Whether the parties’ settlement and the subsequent compromise decree left any dispute requiring adjudication in the writ petitions

Source reference: paras. 4, 6

2. Whether the Court should adjudicate the petitioners’ challenge to the revenue order on the grounds raised, notwithstanding the settlement

Source reference: paras. 2, 6
03

Law Applied

The compromise decree was made on an application under Order XXIII Rule 3 of the Code of Civil Procedure, 1908, which provides for recording a lawful compromise in a suit

Source reference: para. 5

The Court treated the settlement, as recorded in the decree, as resolving the dispute to the extent of its terms; it identified no precedent or separate substantive rule governing the original revenue-order challenge

Source reference: para. 6
04

Reasoning

The Court noted that the petitioners were absent and that respondents 5 and 6 relied on the compromise decree disposing of the civil suit

Source reference: paras. 3–4

On examining that decree, the Court found that the parties’ dispute concerning the subject land had been settled to the extent recorded in the compromise.

Source reference: para. 6

It therefore considered further adjudication of the writ petitions unwarranted and did not decide the merits of the challenge to the revenue order

Source reference: para. 6
05

Holding

The Court disposed of all three writ petitions as infructuous, finding that nothing further survived for consideration following the settlement and compromise decree

There was no order as to costs

Source reference: para. 8
Chhattisgarh High Court

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Devnarayan PatelvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · October 16, 2026

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